Montana v. Egelhoff

PETITIONER: Montana
RESPONDENT: Egelhoff
LOCATION: Rhode Island General Assembly

DOCKET NO.: 95-566
DECIDED BY: Rehnquist Court (1986-2005)
LOWER COURT: Montana Supreme Court

CITATION: 518 US 37 (1996)
ARGUED: Mar 20, 1996
DECIDED: Jun 13, 1996

ADVOCATES:
Ann Celestine German - Argued the cause for the respondent
Joseph P. Mazurek - Argued the cause for the petitioner
Miguel A. Estrada - Argued the cause for the United States, as amicus curiae, supporting the petitioner

Facts of the case

James Allen Egelhoff was tried in Montana courts for two counts of homicide. Egelhoff claimed that extreme intoxication rendered him physically incapable of committing or recalling the crimes. Montana law did not allow Egelhoff's intoxicated condition to be considered. Subsequently, Egelhoff was found guilty. The Supreme Court of Montana reversed the decision. It held Egelhoff had a due process right to present all relevant evidence. Moreover, it held that Montana law's denial of such a presentation relieved the state from part of its burden of proof needed to convict Egelhoff.

Question

May a state restrict the elements of a defense in criminal prosecution, consistent with the Fourteenth Amendment Due Process Clause?

Media for Montana v. Egelhoff

Audio Transcription for Oral Argument - March 20, 1996 in Montana v. Egelhoff

Well, is--

Ann Celestine German:

We're not allowing the word, exculpate, excuse, defend... we're not allowing an intoxicated defendant to come in and say, I am not criminally responsible, that we might say, for instance, to somebody who has some other infirmity.

Miguel A. Estrada:

--to have changed their view.

Ann Celestine German:

All we're saying is that, as this Court has held in other cases, with respect to the proof of this mental state, I want to be able to say to the jury, you've got to consider whether or not I in fact was aware, given my level of intoxication, and if... and if this Court's rules or precedent on proof beyond a reasonable doubt of all essential elements is to be applied to this case, it seems to me the Montana supreme court's interpretation of their statute in the application of these rules, these precedents has to be affirmed.

--Is... do you think that position that in fact there is a change in the meaning of purpose and knowing, and so on?

Ann Celestine German:

If you want to go further--

Is that consistent with what the State court found or construed?

I don't understand, really, the distinction between the affirmative defense--

Miguel A. Estrada:

Yes, Justice Souter, and the reason is this.

Ann Celestine German:

--Okay.

Miguel A. Estrada:

The thing that the State court did wrong in the first place was to use Winship and that line of cases as the first step in the analysis, rather than the last step of the analysis.

--and, I can disprove intent by showing I was dead drunk.

Miguel A. Estrada:

In the usual case we give to the States the power to determine what are the elements of criminal responsibility, and based on the elements as they fashion them, then hold them to the reasonable doubt standard.

Are you... you say that those two are discrete, and maybe in the abstract I can think of them that way, but in concrete I can't, if you're using the drunkenness to show he could not have formed the mental intent necessary to be deliberate.

Miguel A. Estrada:

Here, the State court never really got to the question of whether there has been a change in the State law, because it simply jumped to the conclusion that, to the extent that there had been one, it was barred by Winship.

Ann Celestine German:

Okay, Justice Ginsburg, I'll give you an example of the practical effect.

Miguel A. Estrada:

In our view that was, in a sense, putting the cart before the horse, because it was using a test from these case... from this Court's cases that is directed at the last step of the analysis as the first step, and what it should have done to start with the analysis rightly was to recognize that the proper test was whether this change in the substantive conception of criminal liability was consistent with the history and tradition of our people, which is--

Ann Celestine German:

When you're trying a case, in a criminal case to the jury, the state has the burden of proof to uphold with the evidence, and in Martin v. Ohio I think in fact this language was used, that the State survives the motion to acquit at the end of the State's case.

Well, do you say that the State no longer in Montana has to prove knowing and purposely killing?

Ann Celestine German:

All that time what you're doing, the State has the burden to prove the elements beyond a reasonable doubt.

Miguel A. Estrada:

--Yes, they do, but what they do is that they have a conception of knowledge and purpose from which the effects of voluntary intoxication have been extracted, which is not all that different from how the common law dealt with the concept of malice aforethought.

Ann Celestine German:

The defense is constantly raising doubts, constantly trying to raise reasonable doubt, constantly, with respect to every piece of evidence that comes in.

Miguel A. Estrada:

One could equally well have said that at common law being completely intoxicated was as relevant in a logical sense to whether one could form malice aforethought.

Ann Celestine German:

At the end of the State's case, the defendant sits down and said, I have no evidence to present.

Can you tell me, Mr. Estrada, has... what... has the State here said in effect that this knowledge and purpose is usually present in the intoxicated person, and the jury can usually find it despite the fact of the intoxication, or has it said that we don't care about conscious purpose if the person is intoxicated?

Ann Celestine German:

The burden's on the State, it's got to find beyond a reasonable doubt.

It's not clear to me the logical and the common sense basis for the common law rule that you're proposing.

Ann Celestine German:

I don't have any burden.

Miguel A. Estrada:

Well, let me indicate two possible points.

Ann Celestine German:

I'm sitting here waiting for a verdict.